In Tobe v. City of Santa Ana (1995) 9 Cal.4th 1069, the California Supreme Court rejected the plaintiffs' Eighth Amendment claim because it was not shown that the plaintiffs had no alternative to homelessness, to the conduct that led them to homelessness, or to the violations under the ordinance. (Tobe, supra, 9 Cal.4th at pp. 1105-1106.) The Supreme Court reached that conclusion despite evidence that on any given night at least 2,500 homeless persons in the city did not have shelter beds available to them. (Id. at p. 1083.)